https://www.taxtmi.com/caselaws?id=779964 Receipts from software sales and cloud-based subscriptions supplied under a non-exclusive, non-transferable distribution model were held not to be fees for technical services. The arrangement gave distributors only resale rights, with no power to sub-licence, modify, reverse engineer, or otherwise exploit copyright, and any support was merely ancillary to installation and maintenance. Because the supply involved delivery of software products through licence keys and cloud access without a real human service element or direct human intervention, the receipts were characterised as consideration for sale of software simpliciter rather than technical services under Article 12(3)(b) of the India-Ireland DTAA or section 9(1)(vii) of the Income-tax Act. en-us Mon, 22 Sep 2025 00:00:00 +0530 Thu, 16 Oct 2025 08:30:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=779964 Receipts from software sales and cloud-based subscriptions supplied under a non-exclusive, non-transferable distribution model were held not to be fees for technical services. The arrangement gave distributors only resale rights, with no power to sub-licence, modify, reverse engineer, or otherwise exploit copyright, and any support was merely ancillary to installation and maintenance. Because the supply involved delivery of software products through licence keys and cloud access without a real human service element or direct human intervention, the receipts were characterised as consideration for sale of software simpliciter rather than technical services under Article 12(3)(b) of the India-Ireland DTAA or section 9(1)(vii) of the Income-tax Act. Case-Laws Income Tax Mon, 22 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=779964